TMI Blog2014 (6) TMI 171X X X X Extracts X X X X X X X X Extracts X X X X ..... xport of article or thing outside India has to be excluded both from export turnover as well as total turnover while computing exemption u/s 10A of the Act – thus, the order of the DRP is upheld – Decided against Revenue. - ITA. No. 38/Hyd/2014 - - - Dated:- 16-5-2014 - Shri B. Ramakotaiah, A.M. And Saktijit Dey, J.M.,JJ. For the Petitioner : None For the Respondent : Smt. S. Padma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es for the reason that as per Explanation-2 (iv) of section 10A, any expenditure incurred towards telecommunication charges attributable directly to the export of article or thing outside India has to be excluded from the export turnover for the purpose of claiming exemption u/s 10A. Accordingly, he Assessing Officer computed the exemption u/s 10A by reducingRs.32,57,501/- from the export turnover ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the purpose of computing eligible profits u/s 10A of the IT Act and held that the communication expenses need to be excluded from the exports as per the clause-iv of Explanation-2 to section 10A of I T Act. The telecommunication expenditure does not have element of profit and that it has necessarily to be excluded both from the total turnover and export turnover. Accordingly, the Assessing Officer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rein it is held that communication charges attributable directly to the export of article or thing outside India has to be excluded both from export turnover as well as total turnover while computing exemption u/s 10A of the Act. In view of the ratio laid down as above, the finding of the DRP on this issue is upheld and ground raised by the Revenue is dismissed. 7. In the result, the department ..... X X X X Extracts X X X X X X X X Extracts X X X X
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